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Regulatory Landscape

In 2026, the NAIC Life Insurance and Annuities (A) Committee, chaired by Iowa and vice chaired by Michigan, is largely focusing on annuity sales practices, including annuity buyers guides, suitability, and annuity illustrations. Of particular interest to the life and annuity industry is the formation of the Life Insurance and Annuities Illustrations (A) Working Group (Working Group) chaired by Minnesota. The Working Group’s current charge is to “evaluate concepts for improving life insurance and annuity illustrations and disclosures, and consider revisions to relevant NAIC models or develop other guidance where feasible and appropriate.” The Working Group has asked for input on how to ensure that indexed annuity illustrations give consumers reasonable expectations, after regulators observed materials suggesting annual returns of 10–25% for multiple years. The comment record — including responses from industry trades, actuarial bodies, consumer advocates, and vendors — strongly suggests that current practices around indexed annuity illustrations and disclosures will be revisited. The Working Group is considering short-term and long-term approaches designed to ensure consumers receive reasonable expectations for indexed annuity returns at the point of sale.Read More NAIC Signals Potential Tightening of Annuity Illustration Practices

On February 9, 2026, the House of Representatives, in a bipartisan vote, approved H.R. 3682. This bill would place additional guardrails on the Financial Stability Oversight Council (FSOC) in designating insurance companies as systemically important financial institutions (SIFI). The FSOC was established in the aftermath of the 2008 financial crisis, to identify risks to financial stability, promote market discipline, and respond to emerging threats to financial stability. A key authority of the FSOC is its ability to designate nonbank financial institutions as SIFIs.Read More Bill to Limit Classification of Insurers as ‘Systemically Important’ Receives Bipartisan Approval by the House

We are pleased to invite you to our next edition of the InsurTech Legal Academy to address the use of captive insurance and reinsurance companies by InsurTechs. We are pleased to have Brady Young, Chief Executive Officer, Strategic Risk Solutions, the world’s largest independent captive manager with offices in multiple countries, joining us on this panel discussion. Captive insurance financing is important yet involves complex issues and careful consideration of those.

We hope you can join us.Read More Join Us for Our Next InsurTech Legal Academy Webinar: Captive Insurance Companies for InsurTechs

On January 22, the U.S. House of Representatives passed on a bipartisan basis HR 7148, the Consolidated Appropriations Act, 2026 (HR 7148). If it also wins passage in the Senate, the bill would, among other Trump administration priorities, impose new rules and requirements for pharmacy benefit managers (PBMs) and pharmacy benefit administration more generally. As with prior federal legislative proposals, HR 7148 attempts to bring more transparency to the administration of pharmacy benefits for both fully insured and self-funded groups and would impose enhanced transparency requirements for PBMs contracting with Medicare Part D prescription drug plans PDP sponsors. Specifically, among other requirements, HR 7148 proposes the following new rules and regulations impacting PBM arrangements:Read More House Passes HR 7148, Advancing New PBM Transparency and Compensation Rules

Current Texas Insurance Commissioner Cassie Brown announced this week that she will be retiring on February 2. Brown has led the Texas Department of Insurance (TDI) for the past four years, and her tenure with TDI has spanned many more. Before serving as commissioner, Brown was the commissioner of TDI’s…

Read More Texas Will Have a New Insurance Commissioner

On October 10, 2025, the Connecticut Department of Insurance (the Department) issued Bulletin SL-6 (the Bulletin) to restate the requirements generally applicable to surplus lines placements, and to advise that the diligent effort exception established by Public Act 25-87, effective October 1, 2025, only applies to surplus lines brokers when they procure insurance coverage through an unaffiliated wholesale broker. The Bulletin additionally supersedes and rescinds Connecticut Bulletins SL-3 and SL-5.Read More When Surplus Lines Brokers Are Off the Hook: Connecticut Department Issues Bulletin on New Diligent Effort Exception

On August 20, 2025, the Colorado Division of Insurance (Division) amended Regulation 10-1-1 to expand its existing limited applicability to insurers offering individual life insurance to apply to insurers offering private passenger auto and health benefit plans effective October 15, 2025. Evidence of compliance with the amended regulation must be made available to the Division upon request for private passenger auto and health benefit plan insurers beginning on July 1, 2026.Read More Colorado Division of Insurance Expands AI Governance and Framework Regulation to Private Passenger Auto and Health Benefit Plan Insurers

On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that escalating global conflicts are intensifying threats to the U.S. financial system. The letter highlights increased risk from destructive cyberattacks, sanctions evasion, and illicit activity involving virtual assets. NYDFS urges institutions to take immediate, proactive steps to strengthen operational resilience, ensure compliance, and protect the financial sector from geopolitical spillover.Read More NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

On June 13, Florida Gov. Ron DeSantis signed House Bill 1549 into law. Among other things, the bill has removed the “diligent effort” requirement applicable to surplus lines agents.Read More Florida Bill Eliminating the Surplus Lines Diligent Effort Requirement and a Discussion on Surplus Lines Regulation Trends

Delaware has recently enacted legislation concerning the registration of trade names or “doing business as” names (DBA). This new process mandates that DBAs be registered online through the OneStop application. The Delaware Department of Revenue (DOR) will oversee the statewide DBA registry.Read More To Re-Register Your DBA or Not: That Is the Question in Delaware as New Law’s Effective Date Gets Pushed